Public Commentary

The MSRB periodically publishes letters to Congress and government agencies, Congressional testimony or opinion articles in news publications.

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Congressional Testimony and Letters

Letter to Congress on the MSRB's Fiscal Year 2018 Regulatory Agenda and
Public BudgetJanuary 23, 2018
MSRB Board Chair Lucy Hooper sent a letter on behalf of the MSRB to the Senate Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services to provide an update on recent MSRB rulemakings and provide a copy of the Executive Budget Summary. Read the letter.

Examining the Agenda of Regulators, Self-Regulatory Organizations and Standards-Setters for Accounting, Auditing and Municipal Securities
U.S. House Financial Services Subcommittee HearingSeptember 22, 2016Read written testimony submitted by the MSRB.

Letter to Congress on MSRB's Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection ActSeptember 19, 2016
MSRB Board Chair Nat Singer sent a letter on behalf of the MSRB to the Senate Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services to provide an update on the MSRB's implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The letter outlines the MSRB's development of a regulatory framework for municipal advisors and details the MSRB's municipal entity protection efforts. Read the letter.

Letter to Congressional Task Force on Economic Growth in Puerto RicoSeptember 2, 2016
MSRB Executive Director Lynnette Kelly sent a letter on behalf of the MSRB to the Congressional Task Force on Economic Growth in Puerto Rico to discuss the importance of a robust, transparent and fair municipal market for sustained economic growth in Puerto Rico. The letter outlines a set of principles, informed by MSRB regulatory, transparency and education initiatives, recommended for consideration by Puerto Rico, its bonding authorities and any municipal securities issuer seeking to enhance investor confidence.Read the letter.

Letter to Congress on Comprehensive Rules for IntermediariesFebruary 6, 2009
The MSRB submitted a letter to Congress with recommendations to develop a regulatory structure that governs municipal market participants that provide certain key services to state and local government issuers.Read the letter.

Regulatory Comments and Recommendations

Letter to the Securities and Exchange Commission (SEC) Investor AdvocateOctober 17, 2017
MSRB Executive Director Lynnette Kelly sent a letter to the SEC's Office of the Investor Advocate in response to a request for the MSRB to identify products and practices within the municipal securities market that may have an adverse impact on retail investors. Read the letter.

Comment Letter to the Governmental Accounting Standards Board (GASB) September 7, 2017The MSRB submitted a comment letter to the GASB in response to the organization's ongoing research and outreach efforts on the topic of disclosure by state and local government bond issuers related to debt, including direct borrowings and direct placements.Read the comment letter.

Comment Letter to the Securities and Exchange Commission on Proposed Amendments to Exchange Act Rule 15c2-12April 14, 2017The MSRB submitted a comment letter to the SEC on proposed amendments to require issuers and obligated persons to post event notices that would include their incurrence of a material bank loan or direct purchase of municipal securities.Read the comment letter.

Letter to the Securities and Exchange Commission (SEC) Investor AdvocateNovember 3, 2016
MSRB Executive Director Lynnette Kelly sent a letter on behalf of the MSRB to the SEC's Investor Advocate in response to a request for the MSRB's perspective on products and practices within the municipal securities market that may have an adverse impact on retail investors. The MSRB's letter identifies disclosure practices, price fairness and transparency, types of ownership of municipal bonds and senior investor protection as areas of particular concern. Read the letter.

Letter to the Governmental Accounting Standards Board (GASB)April 25, 2016In response to the GASB's research on debt disclosures, MSRB Executive Director Lynnette Kelly advised the organization of the MSRB's efforts to increase voluntary disclosure by state and local government bond issuers of additional debt and debt-like obligations. The MSRB believes such disclosure is essential to foster a fair and efficient municipal securities market. Read the letter.

Letter to Securities and Exchange Commission Investor AdvocateOctober 30, 2015
MSRB Executive Director Lynnette Kelly sent a letter on behalf of the MSRB to the Securities and Exchange Commission's Investor Advocate in response to its request for the MSRB to identify products and practices within the municipal securities market that may have an adverse impact on retail investors.Read the letter.

Comment Letter on Securities and Exchange Commission Draft FY 2014-2018 Strategic PlanMarch 19, 2014MSRB Executive Director Lynnette Kelly submitted a comment letter on behalf of the MSRB in support of the municipal market goals of the SEC's draft strategic plan for fiscal years 2014-2018.Read the comment letter.

Comment Letter on Securities and Exchange Commission Proposed Regulation Systems Compliance and IntegrityJune 28, 2013The MSRB submitted a comment letter on the SEC’s proposed rule to require certain key market participants to have comprehensive policies and procedures in place surrounding their technological systems.Read the comment letter.

Potential Improvements to Market Structure for Municipal SecuritiesSecurities and Exchange Commission Roundtable on Fixed Income MarketsApril 16, 2013MSRB Executive Director Lynnette Kelly participated in a roundtable discussion on potential improvements to the market structure for municipal securities at the SEC.Read the written statement submitted by the MSRB.

Comment Letter on the Volcker RuleJanuary 31, 2012The MSRB submitted a letter to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the SEC urging expansion of the draft “Volcker Rule” to include governmental obligations exemption to include all municipal securities. Read the comment letter.

Letter to the Securities and Exchange Commission on Municipal Advisory ActivitiesNovember 9, 2011
The MSRB submitted a letter to the SEC on the activities of municipal advisors to assist the SEC with finalizing its definition of “municipal advisor.”Read the letter.

Letter to the Securities and Exchange Commission on Municipal Market DisclosureAugust 8, 2011 The MSRB submitted a letter to the SEC with recommendations on municipal market disclosure that would provide investors with additional information about municipal securities in both the primary and secondary markets.Read the letter.

Opinion Articles

Op-ed in The Bond Buyer on Self-Regulation in the Municipal Securities MarketJanuary 22, 2018
MSRB Chair Lucy Hooper published an op-ed in The Bond Buyer, the news outlet covering the municipal market, to share the MSRB’s perspective as the self-regulatory organization for the municipal market and to contribute to the ongoing dialogue about self-regulation in the U.S. capital markets.

Op-ed in The Bond Buyer on Rule Maintenance and ModernizationJune 26, 2017
MSRB Executive Director Lynnette Kelly published an op-ed in The Bond Buyer, the news outlet covering the municipal market, discussing the MSRB's approach to keeping its regulations for municipal securities dealers and municipal advisors up-to-date.

Column in the Journal of Government Financial Management on Accountability in Municipal FinanceJune 21, 2017
MSRB Executive Director Lynnette Kelly published a column in the Journal of Government Financial Management, the quarterly publication from the Association of Government Accountants, discussing the importance of disclosure by municipal securities issuers. Copyright 2017. Association of Government Accountants. AGA® and the Journal of Government Financial Management® are registered trademarks. Republished with permission. All rights reserved.

Op-ed in The Hill on Infrastructure FinanceJune 9, 2017
MSRB Executive Director Lynnette Kelly published an op-ed in The Hill, a national source for policy and political coverage, discussing infrastructure finance policy considerations.

Op-ed in The Bond Buyer on Pay-to-Play PracticesAugust 4, 2016
MSRB Board Chair Nat Singer published an op-ed in The Bond Buyer, the news outlet covering the municipal market, addressing the MSRB's recent rulemaking to sever the link between giving of political contributions and awarding of municipal advisory business.

Op-ed in Governing Magazine on Bank Loan DisclosureMay 13, 2016
MSRB Executive Director Lynnette Kelly published an op-ed in Governing, a national magazine for state and local government leaders, warning of the risks of inadequate bank loan disclosure by municipal securities issuers.